centro de periodismo investigativo | centro de …...nor definitive: 1) umg – estimated income...

Case 1:11-cv-24142-PAS Document 320-1 Entered on FLSD Docket 10/21/2015 of 36

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2. Identify the amount of shares you have ever owned, directly or indirectly, of any

domestic or foreign company within the past four years, the number of shares you currently own, directly or indirectly, the date that you sold any shares of stock within the past four years, the amount of money you received for such sale of shares of stock, and the name and contact information of any recipient of any transfers of such shares. Not applicable / None

3. Identify all real property and vehicles owned or leased by you within the past four years, the current location and value of such property, any and all identifying documentation such as deeds or title, and to the extent any real property or vehicles have been transferred to another owner in the last four years, the contact information of the recipient and the value received by you for the transfer of such real property or vehicle. Not applicable / None

4. Identify any and all checking, savings, passbook, certificate of deposit, or other bank or financial accounts held in your name, or accounts in any name over which you have or have had signatory authority or other such control, in the past five (5) years, the institution where such bank account is held, and the current balance in each such account. 1) Scotia Bank – Checking Account # 3142,

Current Balance: $824,629.17.

2) Oriental Bank – Checking Account # 9698 Current Balance: $9,990.00 Savings Account # 9698 Current Balance: $969,383.11

5. Identify all credit, debit and/or ATM cards which you use or as to which you have

as to which you have signatory authority or other such control, wherever located and regardless of whose name appears on the account(s), in the past five (5) years. Not applicable / None

6. Identify all domestic and/or foreign trusts in which you are or have been a settlor, trustee, trust protector, and/or beneficiary in the past five (5) years. Not applicable / None

7. Identify all limited partnerships in which you have or have had an interest at any time in the past five (5) years. Not applicable / None

8. Identify, and produce copies of, all journals, books, receipts, and any other documents reflecting, stating, identifying, and/or describing: (a) assets located in the United States which you possess (or have possessed at any time over the past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other persons, entities, or nominees; and (b) assets located outside the United States which you possess (or have possessed at any time over the

REDACTED

REDACTED

REDACTED


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past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other persons, entities, or nominees. (a) Not applicable / None (b) Not applicable / None As for Intellectual Property assets, please review answer to Interrogatory #13.

9. Provide a list of any person or entity that received any assets from you, in whatever title, valued at $1,000 or more within the last four (4) years. Please review the attached documentation, which includes the Puerto Rico Tax Forms 480.6A or 480.6B for the years requested excluding 2014. The 2014 Forms 480.6 will be furnished in the upcoming weeks, as they are not yet due and are being prepared currently.

10. Identify all entities and/or individuals from which you have received royalties or any other payments relating to Daddy Yankee’s music (sale, broadcasting, etc.) within the past ten (10) years, and state the amount of that income.

The interrogatories are so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. To comply with the request would be an undue burden and expense on the defendant. The request is calculated to annoy and harass defendant.

Also, the interrogatory is objected because it would necessitate the preparation of a compilation, abstract, audit or summary from documents in defendants’ possession; because such preparation would be similarly burdensome and/or expensive to both the propounding and responding parties, defendant herewith offers to permit review of the documents enclosed from which propounding party can audit, inspect, copy or summarize. Responding party is making said documents available for review with the notification of this interrogatory.

Nonetheless, defendant proposes an estimated list that is neither all inclusive nor definitive:

1) UMG – estimated income $10,000,000

Contact information: Mr. Mark Berger Esq., V.P. Business Affairs Universal Music Latin Entertainment 5820 Canoga Ave, Suite #300 Woodland Hills, CA 91367 818-577-4794

2) EMI - estimated income $350,000

Contact information: Mr. Mark Berger Esq., V.P. Business Affairs Universal Music Latin Entertainment 5820 Canoga Ave, Suite #300 Woodland Hills, CA 91367 818-577-4794


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3) Itunes - estimated income $1,000,000

Contact information: Apple Inc. 1 Infinite Loop, Cupertino, California 95014 http://itunesconnect.apple.com/

4) Digital Rights Agency- estimated income $500,000

Contact information: Digital Rights Agency Lizy Reierson 1539(a) Folsom Street San Francisco, California 94103 415-864-1756 586-283-6925 (FAX)

5) Orchard - estimated income $350,000

Contact information: Digital Rights Agency Lizy Reierson 1539(a) Folsom Street San Francisco, California 94103 415-864-1756 586-283-6925 (FAX)

6) Sound Xchange - estimated income $650,000

Contact information: SoundExchange, Inc. Account Services 1121 14th St. N.W., Suite 700 Washington, DC 20005 202-640-5859 (FAX)

7) AdShare - estimated income $100,000

Contact information: GoDigital Records, LLC C/o Legal Dept. 233 Wilshire Blvd, Ste 100 Santa Monica, CA 90401

Fischbach, Perlstein, Lieberman & Almond C/o Robert Lieberman 1875 Century Park East suite 1450 Los Angeles, CA 90067

8) VEVO - estimated income $150,000

Contact information: C/o Alexander D. Kisch 4 Times Square 25th Floor New York, NY 10036


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11. Identify all entities from which you have received royalties or other payments for the use of Daddy Yankee’s image within the past ten (10) years, including, without limitation, advertising campaigns, television, film, radio, or in-person appearances, and the amount of those payments. The interrogatory is objected because it is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. To comply with the request would be an undue burden and expense on the defendant. The request is calculated to annoy and harass defendant. Also, the interrogatory is objected because it would necessitate the preparation of a compilation, abstract, audit or summary from documents in defendants’ possession; because such preparation would be similarly burdensome and/or expensive to both the propounding and responding parties, defendant herewith offers to permit review of the documents enclosed from which propounding party can audit, inspect, copy or summarize. Responding party is making said documents available for review with the notification of this interrogatory.


Western Union - $ 100,000

Contact information: Corporate Headquarters P.O. Box 6036 Englewood, CO 80112 1-720-332-1000

METRO PCS - $ 20,000

Contact information: 2250 Lakeside Blvd. Richardson, TX 75082 USA 1-214-570-5800 [email protected]

COORS - $ 50,000

Contact information: 250 South Wacker Drive Chicago, Il 60606-5888

CITGO - $ 200,000

Contact information: P.O. Box 4689 Houston, TX 77210-4689 1293 Eldridge Parkway Houston, TX 77077-1670 1-800-992-4846 [email protected]

CBS Radio - $ 50,000

Contact information: 1271 Avenue of the Americas FL 44 New York, NY 10020


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212-649-9600 MTV- $ 50,000

Contact information: Viacom 1515 Broadway - 52nd Floor New York, NY 10036 [email protected]

SIRIUS XM - $ 50,000

Contact information: 1221 Avenue of the Americas New York, NY 10020 1-888-601-6296

Clear Channel - $ 50,000

Contact information: Tom Poleman, 32 Avenue of the Americas, 21st Floor, New York, NY 10013 Tres Williams, 125 W. 55th St., 11th Floor, New York, NY 10019

iHeart Radio - $ 75,000

Contact information: Tom Poleman, 32 Avenue of the Americas, 21st Floor, New York, NY 10013 Tres Williams, 125 W. 55th St., 11th Floor, New York, NY 10019

SBS Radio - $ 150,000

Contact information: Albert Rodriguez Chief Operating Officer Pablo Raúl Alarcón Media Center 7007 NW 77th Ave. Medley,FL 33166 Telephone: (305) 644-4800 Fax: (786) 470-1667


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CiFrut - $ 325,000

Contact information: EMBOTELLADOR ATIC S.A. Ave. de la Vega, nº 1, Building 2, 5th floor C.P. 28108 Alcobendas (Madrid), Spain

Verizon

Contact information: 140 West Street New York, NY 10007 1-212-395-1000 1-212-571-1897 (FAX)

Movistar Chile

Contact information: Telefónica Chile S.A., Telefónica Móviles Chile S.A., Providencia 111, Santiago, Chile.

Orbitz

Contact information: 500 W Madison St Ste 1000 Chicago, IL, 60661 United States (312) 894-5000 http://www.orbitz.com

12. Identify all entities from which you have received royalties or payments pertaining to sales of Daddy Yankee-branded items other than music within the past ten (10) years, including, without limitation, video games, cologne, footwear, and clothing, and the amount of those payments. Not applicable / None

13. Identify all intellectual property currently owned by you, or that has been owned by you, in the last four years, directly or indirectly, and the current value of such property. (A) MASTER RECORDINGS (LP)

1) “Barrio Fino en Directo” – Jointly owned with UMG 2) “El Cartel Big Boss” 3)“Prestige” 4) “Mundial” 5) “King Daddy”

(B) MUSIC VIDEOS

1) “Barrio Fino en Directo” – Jointly owned with UMG


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• Gangsta Zone • Machucando • Rompe

2) “El Cartel Big Boss”

• Impacto • Mensaje de Estado • El Jefe • El Mejor de Todos los Tiempos • Ella me levantó

3)“Prestige”

• Lovumba • Limbo • Pasarela • La Noche de los Dos • Ven Conmigo • Perro Salvaje • Llegamos a la Disco

4) “Mundial”

• La Despedida • Descontrol • Grito Mundial

5) “King Daddy” • Palabras con Sentido • Ora por mi • La Nueva y La Ex • La Rompe Carros

USPTO Trademark – “EL CONVOY” I do not have the expertise or knowledge to indicate the current value of such property.

14. Identify all contracts and/or agreements relating to intellectual property identified in response to the preceding question executed and/or entered into by you, directly or indirectly, within the past (5) years, stating the name, address and contact information of all parties involved in those contracts and/or agreements. The contact with UMG is Mr. Mark Berger Esq., Director of V.P. Business Affairs. Enclosed is the contract subscribed with this entity. Confidential Settlement Agreement with Major League Baseball. See answer to Interrogatory #10 Also, find enclosed contracts relevant to the question.

15. Identify all “master” records owned by you, directly or indirectly, the current value of each master, and its location. See answer to Interrogatory #13.


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16. Identify all concerts or other events at which Daddy Yankee has performed in the past five (5) years, and state the amount you were paid for each event. Find enclosed list of concerts. Approximate payment for each oscillates in amount but is estimated at $100,000 per show.

17. Identify all concerts or other events at which Daddy Yankee is expected to perform within the next two (2) years, stating (i) the amounts you were paid and the balance owed for each event; and identifying (ii) the person/s who made payments and/or owe you payments for each event, and the account and institution where those payments were or are expected to be made. 1) Date- February 13, 2015 Place- Barranquilla, Colombia Producer- Cristian Cravitz Rodriguez d/b/a Cravitz Producciones Carr. 42 D # 83B60 Barranquilla, Colombia Amount- $150,000 Currently there are no other scheduled concerts, all dates are tentative.

18. State whether you are aware of any transfers of assets valued at $5,000 or more made by any of the other Defendants in this action within the last three (3) years, and identify each such transfer. Based upon the information readily available, none.

19. Identify any monies owed to you by any person, organization, or legal entity, and state the amount of the debt. The interrogatory is objected because it is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. To comply with the request would be an undue burden and expense on the defendant. The request is calculated to annoy and harass defendant. I cannot specify or indicate the monies that will be owed, as many depend on statements that are yet to be received or tabulated.


1) Itunes - $ 1,500

2) AdShare - $ 10,000

3) VEVO - $ 8,000

4) UNIVERSAL - $ 25,000

5) Digital Rights Agency - $ 250


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Dated: February 6, 2015 POLENBERG COOPER PA

Jon Polenberg, Esq. [email protected] Jude Christopher Cooper, Esq. [email protected] 1351 Sawgrass Corporate Parkway Suite 101 Fort Lauderdale, FL 33323 Telephone: 954-742-9995 Facsimile: 742-9971 PRADO NUNEZ & ASSOCIATES Edwin Prado, Esq. (pro hac vice) [email protected] Del Parque St. 403, 8th Floor San Juan, PR 00912 Telephone: (787) 977-1411 Attorneys for Defendants El Cartel, Ramón Luis Ayala Rodríguez and Icaro Services Inc.


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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on February 6, 2015, a true and correct copy of the foregoing was served to the parties listed below in the manner so stated.

SERVICE LIST Via E-mail WINSTON & STRAWN LLP Eric W. Bloom (pro hac vice) Tomás Leonard (pro hac vice) Margaret Ciavarella (pro hac vice) 1700 K Street N.W. Washington, D.C. 20006-3817 Tel: (202) 282-5000 Fax: (202) 282-5100 [email protected] [email protected] [email protected] ASSOULINE & BERLOWE, P.A. 3250 Mary Street, Suite 100 Miami, Florida 33133 Telephone: (305) 567-5576 Facsimile: (305) 567-9343 By: /s/Daniel E. Vielleville Peter E. Berlowe (FBN 143650) Daniel E. Vielleville (FBN 940496) Attorneys for Plaintiffs Five for Entertainment, S.A., d/b/a Five Live Entertainment, and Diego Hernán de Iraola By: /s/ Edwin Prado Galarza Prado, Núñez & Asociados, P.S.C.


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2. Identify the amount of shares you have ever owned, directly or indirectly, of any domestic or foreign company within the past four years, the number of shares you currently own, directly or indirectly, the date that you sold any shares of stock within the past four years, the amount of money you received for such sale of shares of stock, and the name and contact information of any recipient of any transfers of such shares.

All the shares I own are also part of the conjugal partnership with my wife Mireddys González. In fact, none of my assets are solely owned by me but rather are owned by said conjugal partnership.

El Cartel Records 100% Los Cangris, Inc. 100% DY Merchandising 70% DY Broadcasting 70% There have been no transfers of these shares.

3. Identify all real property and vehicles owned or leased by you within the past four years, the current location and value of such property, any and all identifying documentation such as deeds or title, and to the extent any real property or vehicles have been transferred to another owner in the last four years, the contact information of the recipient and the value received by you for the transfer of such real property or vehicle.

All the real estate I own is also part of the conjugal partnership with my wife Mireddys González. In fact, none of my assets are solely owned by me but rather are owned by said conjugal partnership.

Property located in Puerto Rico:

(1) Calle Jaen property specified in answer to Interrogatory #1 (2) Cataño, Barrio Palmas – estimated value $80,000 (3) Residencial Villa Kennedy ED 5 Apt. 88 – estimated value $10,000 (To

be Provided) (4) Bosques del Río, Trujillo Alto – estimated value $125,000 (5) Summit Hill, Guaynabo – estimated value $175,000 (To be Provided) (6) Urb. Carabalí, Luquillo (home and plot of land) – estimated value

$600,000 (7) Urb. Country Club Calle Yaboa Real #874, San Juan – estimated value

$180,000 (To be Provided) (8) Quintas del Campeche, Calle Trinitaria 701, Carolina – estimated value

$200,000

Property located in Florida:

(1) 2550 Davenport Circle, Kissimme, FL – estimated value $100,000 (To be Provided)

(2) 1717 North Bayshore Circle Apt. ___, Miami FL – estimated value $300,000 (To be Provided)

Find copy of the title for some of these properties attached. Please note, however, that Property Law in Puerto Rico is quite complex and some of the titles are not yet available due to restraints placed by the Puerto Rico Registry of Property, or by virtue of pending bureaucratic procedures. As soon as new titles become available we will promptly inform them

4. State your Social Security number, and produce a copy of your Social Security card.

SS # 1643, see copy of card enclosed. REDACTED


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5. Identify any and all checking, savings, passbook, certificate of deposit, or other bank or financial accounts held in your, your wife’s and/or your children’s name, or accounts in any name over which you have or have had signatory authority or other such control, in the past five (5) years, the institution where such bank account is held, and the current balance in each such account.

(1) Scotia Bank – Checking Account # 9178 (LOS CANGRIS’s

account) -- Current Balance: $424,344.10.

(2) Scotia Bank – Checking Account # 409 – 4049 (Personal account) Current Balance: $175,893.15

6. Identify all credit, debit and/or ATM cards which you use or as to which you have as to which you have signatory authority or other such control, wherever located and regardless of whose name appears on the account(s), in the past five (5) years.

Scotia Bank Business VISA Card from Los Cangris Bank Account, card ending in # 0958 that expires 11/17. See copy enclosed.

7. Identify all domestic and/or foreign trusts in which you are or have been a settlor, trustee, trust protector, and/or beneficiary in the past five (5) years.

Not applicable / None

8. Identify all limited partnerships in which you have or have had an interest at any time in the past five (5) years.

Not applicable.

9. Identify, and produce copies of, all journals, books, receipts, and any other documents reflecting, stating, identifying, and/or describing: (a) assets located in the United States which you possess (or have possessed at any time over the past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other 10 persons, entities, or nominees; and (b) assets located outside the United States which you possess (or have possessed at any time over the past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other persons, entities, or nominees. Assets owned by the Conjugal Partner

• Houses (5) • Furniture and fixtures • Jewerly

10. Please state whether you have been employed in the last four years, including any

consulting work or work which paid on a commission basis, and identify the name, address, telephone number and business purpose of any and all employer(s) or principles in the last four years. For any consulting work or commission-based work, identify the amount of income such work has generated.

See Interrogatory Answer #11, El Cartel

11. Provide a list of any person or entity that received any assets from you, in whatever title, valued at $1,000 or more within the last four (4) years.

The interrogatory is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. To comply with the request would be an undue burden and expense on the defendant. The request is calculated to annoy and harass defendant;

Otherwise refer to Answer to Interrogatory by El Cartel Records, Inc.

REDACTED

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12. Identify all entities and/or individuals from which you have received royalties or any other payments relating to your music (sale, broadcasting, etc.) within the past ten (10) years, and state the amount of that income.


Otherwise refer to Answer to Interrogatory #11 by El Cartel Records, Inc.

13. Identify all entities from which you have received royalties or other payments for the use of your image within the past ten (10) years, including, without limitation, advertising campaigns, television, film, radio, or in-person appearances, and the amount of those payments.


Otherwise refer to Answer to Interrogatory #11 by El Cartel Records, Inc.

Los Cangris - $ 1,000,000

El Cartel - $ 600,000

ASCAP - $ 4,000,000

14. Identify all entities from which you have received royalties or payments pertaining to sales of Daddy Yankee-branded items other than music within the past ten (10) years, including, without limitation, video games, cologne, footwear, and clothing, and the amount of those payments.



15. Identify all intellectual property currently owned by you or your spouse or any of your children, or that has been owned by you, your spouse or any of your children, in the last four years, directly or indirectly, and the current value of such property.



16. Identify all contracts and/or agreements relating to intellectual property identified in response to the preceding question executed and/or entered into by you, directly or indirectly, within the past (5) years, stating the name, address and contact information of all parties involved in those contracts and/or agreements.



17. Identify all “master” records owned by you, directly or indirectly, the current value of each master, and its location.

None. Any “masters” available are located at:

Los Cangris Inc. #874 Calle Yaboa Real Urb. Country Club San Juan PR 00936


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18. Identify all concerts or other events at which you have performed in the past five (5) years, and state the amount you were paid for each event. Find enclosed list of concerts. Approximate payment for each oscillates in amount but is estimated at $ 100,000 per show.

19. Identify all concerts or other events at which you are expected to perform within the next two (2) years, stating (i) the amounts you were paid and the balance owed for each event; and identifying (ii) the person/s who made payments and/or owe you payments for each event, and the account and institution where those payments were or are expected to be made. 1) Date- February 13, 2015 Place- Barranquilla, Colombia Producer- Cristian Cravitz Rodriguez d/b/a Cravitz Producciones Carr. 42 D # 83B60 Barranquilla, Colombia Amount- $150,000 Currently there are no other scheduled concerts, all dates are tentative.

20. State whether you are aware of any transfers of assets valued at $5,000 or more made by any of the other Defendants in this action within the last three (3) years, and identify each such transfer. See El Cartel Answer to Interrogatory #18.

21. Identify any monies owed to you by any person, organization, or legal entity, and state the amount of the debt. The interrogatory is objected because it is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. To comply with the request would be an undue burden and expense on the defendant. The request is calculated to annoy and harass defendant. I cannot specify or indicate the monies that will be owed, as many depend on statements that are yet to be received or tabulated. Nonetheless, defendant proposes an estimated list that is neither all inclusive nor definitive

1) ASCAP – Approximately $ 10,000

2) HC Marketing - Approximately $ 50,000


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6


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Dated: February 6, 2015 POLENBERG COOPER PA Jon Polenberg, Esq. [email protected] Jude Christopher Cooper, Esq. [email protected] 1351 Sawgrass Corporate Parkway Suite 101 Fort Lauderdale, FL 33323 Telephone: 954-742-9995 Facsimile: 742-9971 PRADO NUNEZ & ASSOCIATES Edwin Prado, Esq. (pro hac vice) [email protected] Del Parque St. 403, 8th Floor San Juan, PR 00912 Telephone: (787) 977-1411 Attorneys for Defendants El Cartel, Ramón Luis Ayala Rodríguez and Icaro Services Inc.


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2. Identify the amount of shares you have ever owned, directly or indirectly, of any domestic or foreign company within the past four years, the number of shares you currently own, directly or indirectly, the date that you sold any shares of stock within the past four years, the amount of money you received for such sale of shares of stock, and the name and contact information of any recipient of any transfers of such shares. Not applicable / None

3. Identify all real property and vehicles owned or leased by you within the past four years, the current location and value of such property, any and all identifying documentation such as deeds or title, and to the extent any real property or vehicles have been transferred to another owner in the last four years, the contact information of the recipient and the value received by you for the transfer of such real property or vehicle. The property located at 2481 Eagle Run Drive, Weston, Florida 33327 was originally owned by Icaro Services, Inc. as it was purchased in the year2010. Subsequently, in the year 2011 it was transferred to the conjugal partnership comprised of Edgar Baldiri Martínez and Amanda Lopez. Previous rentals: (1) 1400 Sawgrass Corporate, Parkway, Sunrise FL 33316 (rental) (2) 2900 Glades Circle Suite, Suite 950, Weston FL 33327 (rental) Current rental: (1) 2645 Executive Park, Weston FL 33327 Vehicle: (1) Infinity 2011 (sold approximately in 2013; last registration included) Office Equipment consisting of: Computer, Furniture & Fixtures, Cleaning Equipment were sold on year 2012 for $2,000.

4. Identify any and all checking, savings, passbook, certificate of deposit, or other bank or financial accounts held in your name, or accounts in any name over which you have or have had signatory authority or other such control, in the past five (5) years, the institution where such bank account is held, and the current balance in each such account. (1) Citibank- Weston Florida (embargoed accounts):

6008 6226

(2) Bank of America- Weston Florida # 2035, Active Balance 359.49 May 1, 2014 # 6255, Active Balance: 238.00 @ July 30, 2014 # 6161, Active Balance 39.95 April 30, 2014 (3) Banco Popular, Sunrise Florida

4361, Closed (4) Wells Fargo, FL # 2654

REDACTED

REDACTED

REDACTED

REDACTED

REDACTED

REDACTED

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you have signatory authority or other such control, wherever located and regardless of whose name appears on the account(s), in the past five (5) years. Credit Card/Citibank Mastercard 9802 Debit Card/Citibank 1496

6. Identify all domestic and/or foreign trusts in which you are or have been a settlor, trustee, trust protector, and/or beneficiary in the past five (5) years. Not applicable / None

7. Identify all limited partnerships in which you have or have had an interest at any time in the past five (5) years. Not applicable / None

8. Identify, and produce copies of, all journals, books, receipts, and any other documents reflecting, stating, identifying, and/or describing: (a) assets located in the United States which you possess (or have possessed at any time over the past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other persons, entities, or nominees; and (b) assets located outside the United States which you possess (or have possessed at any time over the past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other persons, entities, or nominees. (a) Infinity 2011 (copy of last registration included-sold approximately 2013) (b) Not applicable / None As for Intellectual Property assets, please review answer to Interrogatory #10.

9. Provide a list of any person or entity that received any assets from you, in whatever title, valued at $1,000 or more within the last four (4) years.


The interrogatory would necessitate the preparation of a compilation, abstract, audit or summary from documents in defendants’ possession; because such preparation would be similarly burdensome and/or expensive to both the propounding and responding parties, defendant herewith offers to permit review of the documents enclosed from which propounding party can audit, inspect, copy or summarize. Responding party is making said documents available for review with the notification of this interrogatory.

Finally, there are certain providers of services that are generic and customary in any line of business, such as janitorial services, accountants or legal services that ought not to be detailed as specified in the instruction, as given information is impertinent and unnecessary for the purposes of the interrogatory.


(1) El Cartel Records f/s/o “Daddy Yankee” – various booking engagements

REDACTEDREDACTED


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Please refer to Answer to Interrogatory by El Cartel Records, Inc. for specific information regarding this entity. (2) Juan Fernando Velazco - various booking engagements Javier Villaba [email protected] +539 999017801 +593 980260229 Carlos Acosta [email protected] +57 3115614706 (3) Luis Lozada f/s/o “Vico-C” - various booking engagements Urbanización Estancias de San Fernando Calle 4 A-18 Carolina, Puerto Rico 00985 (4) Andrea Ramírez – Icaro Services, Inc. employee Contact information is not readily available lost all contact. (5) Mi Artista Booking, Inc. Pedro Santana Villas de Ciudad Jardin Buzon 9603 Canovanas, PR 00729

(6) Carlos Crespo Contact information is not readily available (7) Richard De La Font Agency 4845 S Sheridan Rd, Ste 505, Tulsa, OK 74145 http://delafont.com/ (918) 665-6200 (8) AMNI Corporation Contact information is not readily available

(9) Pina Records PO Box 9406 Caguas, PR 00726 (10) Jorge Martinez 84 Winthrop Dr. Sharbsburg GA 30277 (11) Edwin Prado 403 Calle Del Parque


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San Juan PR 00912 (12) Promovision Music Corp.

10770 NW 66 Street Suite 301, Doral, Florida 33178

(13) Angel Reyes

49 Urb. Pedregales Rio Grande, PR 00693 (14) Edgar Baldiri Martinez 2481 Eagle Run Dr. Weston, Florida 33327

10. Identify all intellectual property currently owned by you or that has been owned by you in the last four years, directly or indirectly, and the current value of such property. 21.25% ownership over the movie “Nadie Sabe lo que Tiene” – find contract attched.

11. Identify all contracts and/or agreements relating to intellectual property identified in response to the preceding question executed and/or entered into by you, directly or indirectly, within the past (5) years, stating the name, address and contact information of all parties involved in those contracts and/or agreements. Please find enclosed contract relevant to the question.

12. Identify all concerts or other events at which artists under your management are expected to perform within the next two (2) years, stating (i) the amounts you were paid and the balance owed for each event; and identifying (ii) the person/s who mad payments and/or owe you payments for each event, and the account and institution where those payments were or are expected to be made. I no longer participate in this sort of commercial activity and therefore I have no concerts scheduled.

13. State whether you are aware of any transfers of assets valued at $5,000 or more made by any of the other Defendants in this action within the last three (3) years, and identify each such transfer. Based upon the information readily available, none.

14. Identify any monies owed to you by any person, organization, or legal entity, and state the amount of the debt. The interrogatory is objected because it is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. To comply with the request would be an undue burden and expense on the defendant. The request is calculated to annoy and harass defendant. I cannot specify or indicate the monies that will be owed, as many depend on statements that are yet to be received or tabulated.


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(1) Re: Money owed for concerts in Colombia of Daddy Yankee and Fernando Velazco

Amount owed: $165,000.00 Debtor and contact information - Harrigson González Sánchez Total Conciertos SAS Av. Carrera 9º Nº 107 A – 12, Piso 4 Carrera 13 Nº 96 – 67, Oficina 304 Bogotá (2) Re: Snoop Dog and friends concert in Medellín, Colombia

Amount owed: $125,000.00 Debtor and contact information – Mr. Kenyatta Poole and Mrs. Jomaris DeJesús 4725 Hanstead Trace, Alpharetta, GA 30022 (3) Re: Breach of contractual obligations

Amount owed: $516,955

Debtor and contact information – Diego Iraola, Plaintiff


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Dated: February 6, 2015 POLENBERG COOPER PA



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2. Identify the amount of shares you have ever owned, directly or indirectly, of any domestic or foreign company within the past four years, the number of shares you currently own, directly or indirectly, the date that you sold any shares of stock within the past four years, the amount of money you received for such sale of shares of stock, and the name and contact information of any recipient of any transfers of such shares. 95% Shares of Icaro Comercializadora Regional de Medios, Bogota Colombia; 95% Shares of Icaro Publicidad & Mercadeo, Bogota Colombia; 50% Shares of Icaro Services, Inc., United States; 50% Shares of Alem Investments, Inc., United States; 100% Shares of Icaro Records, Inc., San Juan, Puerto Rico

3. Identify all real property and vehicles owned or leased by you within the past four years, the current location and value of such property, any and all identifying documentation such as deeds or title, and to the extent any real property or vehicles have been transferred to another owner in the last four years, the contact information of the recipient and the value received by you for the transfer of such real property or vehicle. All properties listed belong to the conjugal partnership comprised of Edgar

Baldiri Martínez and Amanda Lopez. DG 91 #4-20 Apt. 102 Bogota Combia Approximate Value of $200,000 Deed #729; Date: March 22, 2002; Banco Granahorrar Bank, Bogota Colombia Copy of deed included 4505 Will Creek Dr. Winter Springs, Orlando Florida 32708 Suntrust Bank (sold under Short Sale) 2481 Eagle Run Drive, Weston, Florida 33327 Title under: Amanda Lopez and Edgar B. Martinez Approximate Value $600,000 Copy of deed included Nissan 2014, copy of registration included Edgar B. Martínez Volkswagen EOS 2008, copy of registration included Amanda Lopez and Edgar B. Martinez MAZDA 2004 License Plate BND 977, copy of registration not on hand. TOYOTA 2011 FORTUNA, License Plate RLT234, copy of registration not on hand.

4. State your social security number, and produce a copy of your social security card. SS#: 5024 See copy of social security card enclosed.

5. Identify any and all checking, savings, passbook, certificate of deposit, or other bank or financial accounts held in your name, or accounts in any name over which

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you have or have had signatory authority or other such control, in the past five (5) years, the institution where such bank account is held, and the current balance in each such account. (1) Citibank Weston Florida # 1413 Balance – embargoed account (2) Bancolombia, Bogotá Colombia Savings # 2231 Balance $2,240,856.93 (Colombian pesos) Checking 8886 Balance $1,209.29 (Colombian pesos) (3) Chase, Weston, Florida

0695 Balance $1,000 – Checking 3695 Balance $86 - Savings

(4) Wells Fargo, Weston Florida:

8136 Balance 714.00; joint account: Edgar B. Martinez and Amanda Lopez

1584 Balance 1,747.00; joint account: Mateo Martinez and Edgar B. Martinez

7927 Balance -30 account holder: Edgar B. Martinez

1514 Balance $0 joint account: Mateo Martinez and Edgar B. Martinez Please refer to Icaro Services, Inc.’s (“ISINC”) Answer to Interrogatories #4 in relation to ISINC Bank Accounts.


as to which you have signatory authority or other such control, wherever located and regardless of whose name appears on the account(s), in the past five (5) years. Credit Card/Citibank Mastercard # 0258 Debit Card/Citibank 6556 Please refer to Icaro Services, Inc.’s (“ISINC”) Answer to Interrogatories #4 in relation to ISINC credit, debit/ATM cards.

7. Identify all domestic and/or foreign trusts in which you are or have been a settlor, trustee, trust protector, and/or beneficiary in the past five (5) years. Bancolombia, Bogota Colombia Fiducuenta 0685; Balance 153,545.55 (Colombian pesos)

8. Identify all limited partnerships in which you have or have had an interest at any time in the past five (5) years. Icaro Comercializadora Regional de Medios, Bogota Colombia (Inactive) Icaro Services, Inc., Tallahassee, Florida, United States Alem Investments, Inc., Tallahassee, Florida, United States Icaro Records, Inc. San Juan, Puerto Rico, United States.

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9. Identify, and produce copies of, all journals, books, receipts, and any other

documents reflecting, stating, identifying, and/or describing: (a) assets located in the United States which you possess (or have possessed at any time over the past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other persons, entities, or nominees; and (b) assets located outside the United States which you possess (or have possessed at any time over the past five (5) years) or which you control (or have controlled at any time over the past five (5) years) directly or through other persons, entities, or nominees. (a) Infinity 2011 (copy of last registration included-sold approximately 2013) (b) Not applicable / None

10. Please state whether you have been employed in the last four years, including any consulting work or work which paid on a commission basis, and identify the name, address, telephone number and business purpose of any and all employer(s) or principles in the last four (4) years. For any consulting work or commission-based work, identify the amount of income such work has generated. I was the Chief Executive Officer of Icaro Services, Inc. Four years ago I had a salary of $4,000 dollars a month. Two years ago the amount was reduced to $2,000, and currently I receive no salary.

11. Provide a list of any person or entity that received any assets from you, in whatever title, valued at $1,000 or more within the last four (4) years. I sold my Infinity 2011 approximately in 2013 for the amount of $44,000.

12. Identify all intellectual property currently owned by you or that has been owned by you in the last four years, directly or indirectly, and the current value of such property.


13. Identify all contracts and/or agreements relating to intellectual property identified in

response to the preceding question executed and/or entered into by you, directly or indirectly, within the past (5) years, stating the name, address and contact information of all parties involved in those contracts and/or agreements.


14. State whether you are aware of any transfers of assets valued at $5,000 or more

made by any of the other Defendants in this action within the last three (3) years, and identify each such transfer. None to my knowledge.

15. Identify any monies owed to you by any person, organization, or legal entity, and state the amount of the debt. The interrogatory is objected because it is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. To comply with the request would be an undue burden and expense on the defendant. The request is calculated to annoy and harass defendant. I cannot specify or indicate the monies that will be owed, as many depend on statements that are yet to be received or tabulated. However, please refer to Icaro Services, Inc.’s (“ISINC”) Answer to Interrogatories #14 in relation to monies owed.


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Dated: February 6, 2015 POLENBEG COOPER PA



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centro de periodismo investigativo | centro de …...nor definitive: 1) umg – estimated income...

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